Brian Michael

Morrison & Foerster LLP

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Latest Posts › Self-Disclosure Requirements

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Department of Commerce Announces Changes to Voluntary Self-Disclosure Program that Significantly Alter Disclosure Incentives

Continuing the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) efforts to bolster enforcement and compliance, on April 18, 2023, BIS issued a memorandum announcing significant changes to its voluntary...more

4/24/2023 / Bureau of Industry and Security (BIS) , Department of Justice (DOJ) , Export Administration Regulations (EAR) , Export Controls , Exports , Failure To Disclose , Office of Foreign Assets Control (OFAC) , Self-Disclosure Requirements , U.S. Commerce Department , Voluntary Disclosure

DOJ Revises Its Guidance on Corporate Compliance Programs

On March 3, 2023, the Criminal Division of the U.S. Department of Justice ("DOJ") revised its Evaluation of Corporate Compliance Programs or ECCP (the “March 2023 ECCP”) for the first time since June 2020....more

3/10/2023 / Bring Your Own Device (BYOD) , Compliance , Corporate Governance , Department of Justice (DOJ) , Policies and Procedures , Risk Assessment , Self-Disclosure Requirements

In Revised Corporate Enforcement Policy, DOJ Increases Incentives for Voluntary Self-Disclosure and Cooperation

On January 17, 2023, the Assistant Attorney General (AAG) for the Criminal Division of the U.S. Department of Justice (DOJ), Kenneth Polite, Jr., announced that DOJ had made “significant changes” to its Corporate Enforcement...more

1/19/2023 / Anti-Corruption , Corporate Governance , Department of Justice (DOJ) , Enforcement Actions , FCPA Corporate Enforcement Policy (CEP) , Foreign Corrupt Practices Act (FCPA) , Self-Disclosure Requirements , Whistleblowers

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